Tech Corner: Elementary Neutralization Units: Benefits and Requirements


While the EPA normally prohibits hazardous waste treatment without a permit, in Maryland one rare exception can be found.  Using an ENU under certain conditions and meeting certain requirements in Maryland help some generators of hazardous waste lower disposal cost and sometimes even generator status designation.

An Elementary neutralization unit is defined as a device which is used for neutralizing wastes which are hazardous only because they exhibit the corrosivity characteristic and is a tank, tank system, container, transport vehicle, or vessel.  In order to reap the extended benefits of using this equipment you must meet the following requirements:
1.       The waste must only be corrosive characteristic (D002).  If the waste is hazardous for any other reason (ie. Toxic in addition to corrosive), the benefits cannot be applied.
2.       The waste must be treated in an ENU immediately upon generation (ie. from point of generation directly into an on-site ENU).  If the waste is stored for some period of time before being managed in an ENU, the benefits cannot be applied.
3.       The ENU must meet standards defined in the regulations.

What are the benefits?
·         RCRA treatment permit is NOT required to treat corrosive “only” hazardous waste in an ENU.
·         Waste treated does not count towards determining generator status which could mean a lower generator status designation and less stringent regulation on your other hazardous waste.
·         Cost-saving with on-site ENU treatment vs. off-site transport and disposal.

One must still keep in mind that although immediately treated waste inside an ENU doesn’t count toward determining generator status, it is still required to be recorded and reported on your Biennial Report if you are required to file one.  Also, any wastes generated as a result of the neutralization process (ie. precipitated solids) must be managed appropriately including as hazardous waste if is determined as such.  Lastly, please consider the rise in wastewater production with the implementation of ENU use; simply directing down a drain may be subject to additional wastewater regulations based on local laws and your local wastewater facilities processing capacity.  In some places you may be required to get a wastewater discharge permit or need to have it trucked to a wastewater treatment facility that can handle the capacity.

As always, each state authority that has adapted the same exceptions and benefits of using an ENU under these circumstances may have varied limitations and allowances.  Contact your local Enviroexpert to see how your state views ENU usage today!

Sources: [COMAR 26.13.01.03B(17), COMAR 26.13.01A(3)(g), COMAR 26.13.02.05A(2), COMAR 26.13.02.05A(2)(b), COMAR 26.13.02.05A(3), COMAR 26.13.02.12, COMAR 26.13.02.16—.19, COMAR 26.13.05.01A(3), COMAR 26.13.07.01A]

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